New Jersey received more than $6B of American Rescue Plan Act (ARPA) funds.  Each agency listed above received a portion of these funds to administer a variety of programs aimed at assisting the agency and NJ constituents and businesses in their recovery from the COVID-19 pandemic.

DeLuca Advisory served as the principal and lead to a prime consultant serving as the Integrity Monitor for each agency.  As the IM, we provided the following services:

• Initial and ongoing risk assessments;   
• Evaluation of project performance;   
• Evaluation of internal controls associated with financial management, cash management, acquisition management, property management, and records management capabilities;   
• Validation of compliance with sub-grant award and general terms and special conditions;   
• Review of written documents, such as quarterly financial and performance reports, recent audit results, documented communications with the State, prior monitoring reports, pertinent performance data, and other documents or reports, as appropriate;   
• Review of specific files to become familiar with the progression of the disbursement of funds in a particular program, i.e., are actual expenditures consistent with planned expenditure and is the full scope of services listed in the project work plan being accomplished at the same rate of actual and planned expenditures; 
• Audit applications from businesses for financial assistance to verify the accuracy of the information provided and eligibility of the applicant; and  
• Ensure that subrecipient is retaining appropriate documentation, based on federal and state regulations and guidance, to support fund disbursement.   
  • In some instances, provide and/or identify training for staff in the areas of detection and prevention of fraud, waste, and abuse.  

Following the departure of the County’s CFO for possible financial misconduct, DeLuca Advisory was engaged to:  

1. Perform an independent forensic audit of County finances and accounts to identify any attempted or actual embezzlement or misapplication of funds; and  
2. Assist the County’s newly created Finance Committee in its development of a Committee Charter that will provide for comprehensive financial oversight of the Finance Department and the County’s finances. 

The City of New Orleans (“NOLA” or “City”) City Council requested DeLuca Advisory to perform an investigation into the Advanced Broadband and Smart City Systems, RFP No. 1193 (Request for Proposal) Procurement. The investigation included the review of various documents including electronic files and emails, interviews of a number of public officials, resulting in an Investigative Report that included our investigative findings and recommendations. 

Serve as Integrity Monitors for six not-for-profit homeless shelter providers.

DeLuca Advisory had a contract with the NYC DOI titled “Department of Homeless Services Shelter Provider Integrity Monitorship Engagement.” This contract was entered into in October 2021 for 1 year and extended for an additional year for $2M.  The various services performed include risk assessments, audits, due diligence checks and investigations where requested, of NYC-funded not-for-profit organizations providing homeless shelter and social services to the homeless population. This engagement was initiated following the criminal investigation and prosecution of one of these providers and based on the results of a questionnaire provided by NYC DOI to more than 70 providers covering governance, internal controls, conflicts of interest, and other integrity and governance related matters. DeLuca Advisory was requested to audit six of these providers. In total, these organizations had revenues of more than half a billion dollars.  

The reviews/audit plans included, but were not limited to the following elements: 

1. Review organizational governance policies and procedures and make recommendations where appropriate to implement best practices. 
2. Review policies and procedures, and make recommendations, pertaining to: 

• Financial management 
• Procurement and vendor selection 
• Hiring of new employees 
• Complaint, whistleblower, and hotline administration 
• Complaint investigation and resolution 
• Executive Compensation 

1. Perform sample audits/testing of financial and procurement records.  
2. Perform forensic audits where there are red flags of possible fraud, waste, or abuse.